UAV tracking module proposal based on a regulative comparison between manned and unmanned aviation

JAIRM, 2022 – 12(1), Online ISSN: 2014-4806 – Print ISSN: 2014-4865 https://doi.org/10.3926/jairm.206 UAV tracking module proposal based on a regulative comparison between manned and unmanned aviation Savaş Selahattin Ateş 1, Mustafa Uzgör 2, Kemal Yüksek 3 1Eskişehir Technical University (Turkey) 2Anadolu University (Turkey) 3Directorate General of Civil Aviation in Turkey (Turkey) [email protected], [email protected], [email protected] Received December, 2021 Accepted June, 2022 Abstract Purpose: The aim of this study is twofold. First is to compare manned and unmanned aviation regulations in the context of ICAO Annexes to identify potential deficiencies in the international UAV legislations. Second is to propose a UAV monitoring module work flow as a solution to identified deficiencies in the international UAV regulations. Design/methodology: In the present study, firstly the regulations used in manned aviation were summarized in the context of ICAO Annexes. Then along with an overview of the use of UAVs, international UAV regulations have been reviewed with a general perspective. In addition, a comparison was made on whether contents of ICAO Annexes find a place in common international UAV regulations in order to understand areas to be developed in the international UAV regulations, and to better understand the different principles between manned and unmanned air transport. In the last section, we present a UAV tracking module (UAVTram) in line with the above-mentioned comparison between manned and unmanned aviation and the identified deficiencies in the international UAV regulations. Findings: The international UAV regulations should be developed on the basis of airport airspace use, detection, liabilities, sanctions of violations, and updating of regulation. Proposed UAVTram has potential to offer real-time tracking and detection of UAVs as a solution to malicious use of UAVs. -29- Journal of Airline and Airport Management 12(1), 29-47 Research limitations/implications: Our study is not exempt from limitations. Firstly, we didn’t review all UAV regulations because it needs a considerable amount of efforts to check out all the UAV regulations pertinent to different areas of the world. It is the same case for manned aviation as we used only ICAO Annexes to contextually compare with UAV regulations. Practical implications: From the practical perspective, studies introducing new technologies such as systems that help detection of remote pilots causing trouble and agile defense systems will give valuable insights to remove individual UAV threats. Originality/value: We didn’t find any study aiming to compare manned and unmanned aviation rules in search of finding potential deficiencies in the UAV regulations. Our study adopts such an approach. Moreover, our solution proposal here uses Bluetooth 5.0 technology mounted on stationary transmitters which provides more effective range with higher data transfer. Another advantage is that this work is projected to be supported by Turkish civil aviation authority, DGCA. This may accelerate efforts to make required real-time tests. Keywords: Unmanned Aerial Vehicles, Drone, UAV Regulations, Drone Regulations To cite this article: Ateş, S. S., Uzgör, M., & Yüksek, K. (2022). UAV tracking module proposal based on a regulative comparison between manned and unmanned aviation. Journal of Airline and Airport Management, 12(1), 29-47. https://doi.org/10.3926/jairm.206 1. Introduction Since the beginning of aviation, aircrafts have needed infrastructure for landing, take-off, and various supportive facilities. Airports and heliports are commonly known surface structures. On the other hand, unmanned aerial vehicles (UAVs), which are a product of the technological developments in recent years, especially those with multi-engine rotary vane do not need the landing / take-off areas which are vital in the traditional air transport system. Along with the free movement area in individual use, the increasing prevalence of UAVs paved the way for serious violations such as air collision and closure of airports (Yaacoub, Noura, Salman, & Chehab, 2020). In order to prevent such problems, the authorities have issued their own regulations for the integration of UAVs into the air transport system. Although the enacted UAV legal regulations draw a specific framework of use, the use of UAVs is suitable to create a gap in terms of ethical and legal aspects when considering private sector and individual use such as entertainment aerial photography and mobile internet network coverages (Custers, 2016). The motivation of the present study is based on these diverse use areas of drones and their unpredictable consequences. Despite their benefits, UAVs may cause danger to the privacy and safety of people, structures and manned aircrafts. Incident of a UAV landing on the official residence of Japan’s Prime Minister in 2015 (Nakamura & Kajikawa, 2018) and the closure of Gatwick Airport due to drone activities (Wendt, Voltes-Dorta & Suau-Sanchez, 2020) are among samples showing how crucial it is to establish coordination and control over the UAVs. In order to build a consistent coordination, it is utmost important to establish an up-to-date UAV legislative framework by learning from the past experience and identifying gaps. Herein, International Civil Aviation Organization (ICAO) has been trying to build a global consensus on UAV regulations to consider fundamental differences from manned aviation (ICAO, 2011). DRONE ENABLE Symposiums hosted by ICAO since 2017 are among such efforts. The literature regarding the various aspects of UAVs is vast and growing. While a number of studies review the current state of the art of UAV technologies, some of their salient research themes are UAV routing problems (Ropero, Muñoz & R-Moreno, 2019; Schermer, Moeini & Wendt, 2018; Viloria, Solano-Charris, Muñoz Villamizar & Montoya-Torres, 2021), drone delivery optimization (Ha, Deville, Pham & Hà, 2018; Murray & Raj, -30- Journal of Airline and Airport Management 12(1), 29-47 2020; Otto, Agatz, Campbell, Golden & Pesch, 2018), the history of UAVs (Nonami, 2007), drone-related defense systems (Shi, Yang, Xie, Liang, Shi & Chen, 2018; Wendt et al., 2020), simulation for aerial transportation (Mualla, Bai, Galland & Nicolle, 2018; Mualla, Najjar, Daoud, Galland, Nicolle, Yasar et al., 2019), overviews for specific fields of applications such as precision agriculture (Vroegindeweij, van Wijk & van Henten, 2014; Zhang & Kovacs, 2012) and coastal surveying (Turner, Harley & Drummond, 2016). Specifically, detecting and eliminating UAVs has been investigated widely by industry and the academia to help commercialization of antiUAV applications. Specific systems suggested by researchers present autonomous detection, monitoring and identification. The proposed systems make use of technologies such as radio frequency signals (Nguyen, Ravindranatha, Nguyen, Han & Vu, 2016), LIDAR (Hammer, Hebel, Laurenzis & Arens, 2018), RADAR (Kim, Park, Park, Kim, Jung, Kim et al., 2018; Shin, Jung, Kim, Ham & Park, 2016), audio assistance (Anwar, Kaleem & Jamalipour, 2019; Kim, Park, Ahn, Ko, Park & Gallagher, 2017; Kim & Kim, 2018), and vision-based systems (Demir, Ergunay, Nurlu, Popovic, Ott, Wellig et al., 2020; Unlu, Zenou, Riviere & Dupouy, 2019). A general overview of UAV detection technologies and their pros and cons can be found on studies by Azari, Sallouha, Chiumento, Rajendran, Vinogradov and Pollin (2018) and Guvenc, Koohifar, Singh, Sichitiu and Matolak (2018). In a similar way to our study, among the studies investigating the regulative aspects of UAVs, privacy, safety, and security seem to be among the most salient research domains. According to Kellermann, Biehle and Fischer (2020), there are uncertainties regarding the technical features of UAVs and their potential effects on the environment and societies. Their research results indicated that drone-related risks for safety and security are perceived to be major issues with societal implications, privacy violations, public acceptance etc. Reviewing the aviation law as well as regulations such as soft regulatory frameworks and pre-existing generic laws, Clarke (2014) identified specific privacy risks and threats in civilian use of UAVs in the context of surveillance. He noted that aviation laws fail to provide protection against aerial surveillance and that the privacy concerns are out of scope. Clarke and Moses (2014) reviewed the same regulations in the context of public safety. They proposed a set of criteria for a regulatory regime which would encourage consultation with different stakeholders in order to minimize preventable harms. Nakamura and Kajikawa (2018) evaluated Japan’s regulation of small UAVs (sUAVs), indicating that sUAVs may pose a threat to the safety of manned aviation as well as people, buildings and vehicles. Extending a new safety analysis approach, System-theoretic Accident Model and Process (STAMP), the authors highlighted four issues and suggested alternatives for more effective regulation. Their suggestions include transformation from prescriptive to performance-based regulation, guidance for safe design of UAVs, new and specific requirements for UAV pilots and stimulation of technologies such as communications between sUAVs and sUAV management systems, and collision avoidance systems. By means of a discourse text analysis, Rao, Gopi and Maione (2016) reviewed Federal Aviation Authority’s (FAA) UAV regulations and addressed regulatory, safety, security, privacy, liability, and ownership challenges that arises from civilian UAV applications. They pointed out that digital and physical accident risks are inevitable to multiply as the number of civilian UAVs increases globally. Stöcker, Bennett, Nex, Gerke and Zevenbergen (2017) summarized various legislation practices in individual countries alongside the international regulation and revealed that there are distinct variations in regulations on countrylevel with some common applications. In a similar vein, Srivastava, Gupta, Dikshit and Nair (2019) reviewed India’s UAV regulations in terms of safety, security and privacy, comparing their national drone law with the international drone law. As a result, they suggested a Drone Policy 2.0 which focuses on commercial use of UAVs. Based on defensive perspective regarding the damage caused by malicious UAVs, researchers in this field generally aim to present defensive or counter-attack measures and detection technologies. Kim et al. (2017) presented the real-time sound-based UAV detection, using plotted image machine leaning (PIL) and K nearest neighbors (KNN). According to their simulation results, PIL was found to be more efficient while KNN was less complex. Lee, Jung and Park (2016) proposed detection of amateur UAVs using radars based on pseudo random binary sequence. They give evidence that UAVs can be detected with radar technology in 100 m distance for 2 GHz band. Liu, Wei, Chen, Pan, Lin and Ren (2017) described a mixed audio-assisted statically located detection for micro-UAVs. Their system was consisted of 30 cameras (for location detection) and 3 microphones (for direction detection) and tested against multiple UAVs. -31- Journal of Airline and Airport Management 12(1), 29-47 From the above literature it can be indicated that the radar frequency communication, acoustic measurement, image and video signal processing technologies are generally employed for UAV detection. However, RF based detection fails in severe atmospheric conditions and has limitation of detecting smaller and diverse shaped drones. Similarly, the image and video-based techniques require high performance cameras and computationally efficient circuitry, hence is a very costly solution. Moreover, these image and video-based technique has limitations due to its stationary orientation. The sound-based detection is more practical, but various interfering sound sources like, birds, airplanes, wind, thunderstorm etc., makes it more challenging. Our solution here uses Bluetooth 5.0 technology mounted on stationary transmitters which provides more effective range with higher data transfer. Another advantage is that this work is projected to be supported by Turkish civil aviation authority, DGCA. This may accelerate efforts to make required real-time tests. The aim of this paper is twofold. First is to compare manned and unmanned aviation regulations in the context of ICAO Annexes to identify potential deficiencies in the international UAV legislations. Second is to propose a UAV monitoring module work flow as a solution to identified deficiencies in the international UAV regulations. In the present study, firstly the regulations used in manned aviation were summarized in the context of ICAO Annexes. The annexes are evaluated only by the topics they contain and no detailed information is provided. Then along with an overview of the use of UAVs, international UAV regulations have been reviewed with a general perspective. In addition, a comparison was made on whether contents of ICAO Annexes find a place in common international UAV regulations in order to understand areas to be developed in the international UAV regulations, and to better understand the different principles between manned and unmanned air transport. In the last section, we present a UAV tracking module (UAVTram) in line with the above-mentioned comparison between manned and unmanned aviation and the identified deficiencies in the international UAV regulations. Details regarding the functions of the proposed UAVTram is given in this section. 2. Overview of the UAV Use UAVs are expressed as drone in the media and the public know them as drones. However, drone is not mentioned in any legal legislation (Custers, 2016, p. 11). The drone includes unmanned planes and helicopters with fixed or moving, single or multiple motors, but does not include unmanned balloons, rocket and jet packs. UAVs are mostly used in official documents, including legal regulations. Although they are frequently controlled by a human from the ground, UAVs have a variety of autonomy levels, including those that are completely autonomous. When the history of UAVs is considered, it is seen that it has been used mainly for military purposes since the 1st World War (using radio control techniques). Over time, however, fixed-wing, multi-engine, turbofan energy sources (usually battery) have been increasingly used for both individual and commercial purposes. Today, companies such as Amazon and UPS received approval to operate their fleet in unmanned package delivery. Some of the areas of the use of UAVs are given below (Jha, 2016, p. 15; Yaacoub et al., 2020): • Military discovery, assault and defense, • Use by police and law enforcement agencies to ensure public order, • To ensure border security, • Supply and delivery of critical humanitarian needs in times of disaster, • Emergency response, • Aerial video and photo shoot, • For various recreational purposes by civilians, • Terror and assassination actions, • In oil, gas and mine exploration, • Scientific research in atmospheric environment, • Search and rescue activities, • Environmental management, • Underwater/Maritime purposes. -32- Journal of Airline and Airport Management 12(1), 29-47 Regardless of their application area, UAVs are utilized by a prevalent stimulation to make procedures faster and more flexible, while enhancing accuracy and cost-efficiency (Kitonsa & Kruglikov, 2018). UAVs also have the capability to fly in dangerous environments that would be inaccessible to humans, while respecting the environmental protection. However, operation of UAVs in the above-mentioned scenarios, involves issues such as public safety, security, social, privacy, routing, detection, etc. Today, one of the important duties of decision makers is to legislate integrated up-to-date regulations that will allow benefitting from the advantages of UAVs without disrupting the daily life and business practices. 3. Comparison of the Regulations 3.1. Manned Aviation Regulations in the ICAO Annexes Framework ICAO introduces various rules for civil aviation operations in order to establish minimum common standards in all member countries, to ensure harmonization among countries and to make recommendations, and collects them in Annexes. There are 19 Annexes which are regulated by ICAO and are considered as appendices of Chicago convention agreement. Annexes are explained in brief within the context of issues they pertain in Table 1. Annexes Contents Annex 1 It is related personnel licensing. The authorization to use and maintain manned aircrafts is subject to specific licensing under the related annex of International Civil Aviation Agreement depending on the relevant annex of the Agreement. Other professions that are subject to licensing include air traffic controller, flight operation officer, aviation station operator and aviation meteorological personnel. Annex 1 also states which health conditions are required for which licensing. Annex 2 In conjunction with Annex 11, it establishes rules for the implementation of air navigation services procedures. The general process procedures of aviation such as responsibility and duty of the captain, the protection of persons and property, collision avoidance, flight plans, air traffic control services, illegal interventions, visual flight and instrument flight rules, the use of warning and emergency signs are carried out in consideration of this annex. Annex 3 It describes the meteorology service to be provided for international air navigation. It is aimed to contribute to the safety, regularity and effectiveness of international air navigation. It explains meteorological observations, reports and contents. Aircraft observations, types of estimates, emergency warnings for SIGMET, AIRMET, emergency warnings for airport and runway, communication requirements and technical specifications for all these are included in Annex 3. Annex 4 It includes operational requirements of maps used in aviation, meaning of symbols, measurement units, reading of geographical information, abbreviations, political borders, prohibited, restricted or dangerous areas, typography, airspace boundaries and map specifications related to ground movement area, approach, takeoff and landing areas. Annex 5 It explains the measurement units to be used in air and ground operations. With the aim of making technical communication easier by standardizing, it regulates SI (Systeme Internationale) unit system and non-SI alternative measurement units definitions and applicability. Annex 6 It aims to standardize the international operation of aircrafts to ensure the highest level of safety and efficiency. It is divided into 3 sections. It explains operational facilities, operational certification, flight preparation, flight sequence procedures, the duties of the pilots and the technical equipment to be transported. The first part is related to international commercial air transport aircraft, the second part deals with international general aviation aircraft and the last part is for the international operation facilities for the helicopters. Annex 7 How to classify and define air vehicles, how to specify the aircraft nationality is included in this appendix. Aircraft registration signs, common signs, location and dimensions of markings, types of characters to be used are described here. Annex 8 This annex details the airworthiness requirements of aircrafts, what their contents should be based on the type of eligibility certificate, the responsibilities of the countries in order to maintain airworthiness, the routes to be followed in the certificate applications, the characteristics that the aircraft parts must bear according to the aircraft types. -33- Journal of Airline and Airport Management 12(1), 29-47 Annexes Contents Annex 9 The rules for supporting air transport such as clearance procedures, sojourn conditions, passenger and baggage procedures, travel documents, traffic flow regulations within the airport, procedures to be followed in case of emergencies are described here. Annex 10 Consists of 5 parts and is concerned with communication aids and procedures in aviation. Parts include radio navigation tools in the first part, communication procedures in the second part, digital data and voice communication systems in the third part, radar monitoring and collision prevention system in the fourth part, and how to use aviation radio frequencies in the last part. Annex 11 The classification of airspaces, the procedure to be followed in the air traffic service operation, provisions, responsibilities, routes, air traffic services, the responsibilities of the air traffic control in emergency are explained in Annex 11. Annex 12 Search and rescue services, regions, coordination centers, communication procedures in search and rescue operations, search and rescue units, equipment, the necessity of coordination with other countries or organizations, training of personnel, procedures to be monitored at the time of accident or incident, information marking are explained. Annex 13 Includes investigative procedures that must be followed in an accident or incident involving an aircraft. The importance of the investigation, its independence, the preservation of evidence, the removal of the accident, the responsibilities of the countries, autopsy and medical investigations, coordination with the judicial authorities, protection of records, rights, obligations and reporting constitute the content of this supplement. Annex 14 In this appendix, the certification, design, reference codes, airport data, airport reference point, runway, apron and taxiway physical characteristics, characteristics of other facilities on air and land side, obstacle restriction and removing, visual aids for navigation in airport, the qualifications of the systems needed in electricity for navigation devices, operational airport equipment, services and the way to be followed in the installation of these are included. In the second volume, information is given about the features that the heliports should carry and the procedures to be followed on similar issues. Annex 15 Common reference system for air navigation, exchange of aeronautical data and information, information management in aviation, products and services providing aviation information, updates to be considered are included in this annex. Annex 16 The relationship between aviation and environment is included in this annex under 3 volumes with the theme of protecting the environment. Airborne noise measurement, maximum noise levels, measurement reference point, noise certification procedures are specified depending on different types of aircrafts are included in the first part. In the second part, the rules and emission measurement techniques to be followed in the engine emissions are stated according to various engine types. In the third part, CO2 emission assessment according to aircraft types is explained, maximum permissible values and certification test provisions are included. Annex 17 It is designed to protect international civil aviation against unlawful interference. This appendix includes all the measures to be taken for the screening of passengers and cabin baggage at the gates, scanning of hold luggage, scanning of cargoes, cyber threats, precautions for land side and aircraft. Annex 18 Includes measures to be taken for the safe transport of dangerous goods by air. Hazardous substances, transport restrictions, labeling and labeling, hazardous material handling procedures, responsibilities and training programs are specified here. Annex 19 Safety management responsibilities of the countries, implementation, policy, purpose, commitment and promotion of the safety management system, the way to collect, analyze and share the safety data are explained in this annex. Table 1. Contents of ICAO Annexes (ICAO) 3.2. International UAV Regulations The international regulatory authority in the field of aviation is the International Civil Aviation Organization (ICAO) established in 1947. One of the missions of ICAO is to introduce international standards and practices in aviation and to ensure the development of international civil air transport in a systematic, organized and safe way (Hirst, 2008, p. 48). ICAO has also drawn a regulatory framework called the Unmanned Aircraft System -34- Journal of Airline and Airport Management 12(1), 29-47 (UAS) for the purpose of integrating the rapidly growing UAVs into the aviation system. Accordingly, the UAVs must comply with the air navigation rules in a country airspace and be used in such a way that they do not interfere with the operation of other aircraft. Regulations generally distinguish users as individual and commercial, and there are more restrictive conditions for commercial use of UAVs. All UAV users need to observe, interpret and take into account the various visual signals used to draw their attention (ICAO, 2011, p. 15). UAVs should not restrict access of other aircrafts to airspace. At the same time, the flight plan must be forwarded to the air traffic service provider for the remote-controlled flight. However, this does not refer to individual UAV users. ICAO continues to develop international regulations by taking opinions from countries and international organizations. Eurocontrol, one of the institutions involved in the integration of unmanned aerial vehicle systems into the European aviation network, seeks to establish a regulatory framework for the movement of UAVs in airspace. The Eurocontrol prioritizes the safety of air traffic management and collaborates with ICAO and the European Aviation Safety Agency (EASA). Regulations concentrate on (Eurocontrol, 2019); • Flight rules • The evaluation of air space • Common altitude reference system. Eurocontrol strives to achieve a safe integration with manned air traffic at levels of 500 ft (150 m) and below. Legal regulations for UAVs across the world vary from country to country. However, as of 2019, the European Commission (EC) adopted rules across the European Union, which introduced technical requirements for UAVs and developed a common regulation for UAV applications (EASA, 2018; EC, 2019). This regulation is developed with the DroneRules project and the project aims to increase the awareness of users. DroneRules has divided the users into two (for entertainment and business purposes) and has prepared training videos for issues to be considered accordingly (EU, 2019). The European UAV regulation contains information on UAV regulation regarding safety, privacy and data protection, obligations and insurance requirements (EU, 2019). However, the international UAV regulations seem to be immature and will be under completion process for years depending on the coordination of the authorities and technologic shifts in future. Recently, many countries have introduced new safety, security, and privacy regulations governing the use of UAVs in their national airspace. Regulatory developments often emerge as a response to the rapidly developing market (Eurocontrol, 2019). Alongside the regulative organizations, Global Uncrewed Aircraft Systems Management Association (GUTMA) is another organization that aims to enhance the safe and secure integration of drones in the incumbent airspace systems to promote the transparency in the implementation of globally concordant UTM systems (GUTMA, 2022). GUTMA represents organizations engaged in innovative drone facilities and smart mobility solutions and is open to public and private organizations, as well as regulators, that are involved in unmanned traffic management and drone activities. 3.3. Results of the Comparison There are diverse UAV regulations that were adopted by each country except the attempt of EU-wide DroneRules Project. In Table 2, we show our determinations regarding the contents of UAV regulations in terms of ICAO Annexes. It represents which ICAO Annexes have a place in the international UAV regulations, which do not, and in what way they correlate with each other. -35- Journal of Airline and Airport Management 12(1), 29-47 ICAO Annexes Contents 1. Personnel Licensing Only pilots of UAVs above a specific weight are licensed 2. Rules of the Air Rules for visual contact, safe distance, privacy and respect for restricted areas are specified. 3. Meteorological Service for International Air Navigation Only VFR flights are allowed. User is responsible to pay attention to weather conditions which are not suitable for flight. 4. Aeronautical Charts Current aeronautical charts are being updated. It is aimed to determine a UAV specific symbol. UAV regulations currently does not have a regulation related to aeronautical maps. 5. Units of Measurement to be Used in Air and Ground Operations UAV regulations do not have a unit of measurement specific to the use of UAV. 6. Operation of Aircraft The duties and responsibilities of the pilot are clearly stated. For commercial use, operational manual is mandatory. Special operational requirements such 7. Aircraft Nationality and Registration Marks UAVs over a certain size and weight are required to be registered. In order to be noticed and identified, the UAVs of a certain size are subject to Annex 7. 8. Airworthiness of Aircraft Airworthiness requirements of the UAV apply only to those above a certain size. 9. Facilitation A station or facility and handling procedures that will perform aid and support activities for UAVs are not included in the regulation. However, it is stated that they may be needed in the future. 10. Aeronautical Telecommunications Every UAV that will fly in the controlled airspace should be able to communicate with the air traffic controller and other pilots. There must be an applicable communication device on these UAVs. 11. Air Traffic Services Voice communication between ATC and pilot is required for all aircraft and operations, suitable and transparent to the controller for UAVs over a certain size. 12. Search and Rescue In cases where the UAVs are deemed necessary, they are included in the regulations to be used within the framework of cooperation with other aircrafts in search and rescue activities.. 13. Aircraft Accident and Incident Investigation In the event of an accident or incident, the reports, the duties and responsibilities of the pilot-in-command and the accident notification are included in the regulations. 14. Aerodromes Design and Operations / Heliports The facilities, equipment and features required for certain landing sites of UAVs are not yet included in the UAV regulations. 15. Aeronautical Information Services The UAV regulations do not yet contain information on aviation information publications. 16. Environmental Protection Operations may occur in ad hoc or semi-prepared locations that are away from populated areas. For engine-driven UAVs, engine emission standards as specified in Annex 16 applies. 17. Security As a remote pilot station is similar in purpose and design to a cockpit, it must likewise be secure from sabotage or unlawful malicious interference. The UAV operator and pilot are obliged to ensure the safety of the UAV system and vehicle against external interference. 18. The Safe Transport of Dangerous Goods by Air Most of the dangerous goods carriage requirements included in Annex 18 are considered applicable to UAV’s. At such time as civil UAV’s are utilized for the transportation of goods internationally, the provisions of Annex 18 will be applicable. 19. Safety Management Hazards arising from operating UAV’s must be identified and the safety risks mitigated. As operators introduce UAS into operation, the State Safety Program should support analysis of the potential effect on the safety of unmanned aircraft systems. Table 2. Contents of International UAV Regulations in terms of ICAO Annexes -36- Journal of Airline and Airport Management 12(1), 29-47 As result of the comparison, it has been inferred that international UAV regulations have some deficiencies within the framework of the following themes and these issues are suggested to be improved. (Figure 1). 4. UAV Monitoring Module Proposal UAVTram (UAV Tracking Module) solution consists of hardware, mobile app, software portal and functions. The UAVTram monitoring hardware module uses a technology foundation using Bluetooth 5.0 (BLE) or Long Range (LoRa) wireless technologies. The equipment consists of two separate printed circuit boards (PCBs) as transmitter and receiver. The UAVTram tracking transmitter module is a 3 cm x 5 cm box designed to be mounted on the UAV. UAVTram transmitter module consists of a PCB board, BLE or LoRa chip, GPS module, memory card (internal/micro SD), external battery parts. The UAVTram tracking receiver module is a modem to be installed in critical infrastructures. This modem PCB consists of BLE or LoRa receiver chip, Wi-Fi module and RJ45 cable connection. The purpose of this modem is to transfer the data from the UAVTram tracking transmitter mounted on the UAV to the portal. For UAVs that do not fly near critical infrastructures, it will be able to use other UAV users’ Bluetooth supported mobile phone. Figure 2 shows real parts of our planned module. UAVTram mobile app and portal software are projected to be managed by DGCA. Functions and work flow for UAVTram solution was formed based on the benchmark from manned aviation Annexes. -37Figure 1. Improvement Areas of the International UAV Regulations Journal of Airline and Airport Management 12(1), 29-47 be needed in order to avoid undesirable events. Moreover, since UAV usage is growing at a fast pace with new technologic developments, the UAV regulations should be accordingly updated. Likewise to the study by Rao et al. (2016), lag between the technology and the regulations is deemed evident in our study. These deficiencies may be helpful for decision makers in updating the UAV regulations for a safer air space on airports. In light of our findings, this paper supports Srivastava et al. (2019)’s segregated airspace suggestion which will keep both commercial and individual UAV operations away from manned aviation in controlled air spaces. A controlled droneports in future could be a smart choice for certain sized UAV operations at this point. Apart from studies evaluating tracking and detection methods of UAVs (Guvenc et al., 2018; J. Kim & Kim, 2018; Liu et al., 2017), our study presents a new method to track and detect UAVs, integrating the process with the e-state applications. As a result of our comparison between manned and unmanned aviation, UAV regulations should be improved in the following areas in order to ensure that UAV regulations are more effective: •It should make unmanned flights as safe as the manned flights. •It should not restrain access of airspace to other airspace users. •It must meet certain airspace requirements. •It must be transparent to air traffic control and other airspace users. These elements are in fact the issues discoursed in the UAV regulations in general. However, in practice, it is seen that there is no stable and technical equipment that prevents the abuse of malicious users. As also suggested by Clarke and Moses (2014), it is thought that ICAO will make legal regulations more inclusive with the help of organizations such as EASA, Eurocontrol and national aviation authorities in the elimination of individual UAV threats to manned aviation by taking into consideration the suggestions from all stakeholders including the users. As a solution to these issues, our UAVTram module offers safety, security, airworthiness and sanctions of potential violations of UAVs. UAVTram has potential to offer real-time tracking and detection of UAVs. This module will be able to provide solution to problems indicated in Figure 1. Our study is not exempt from limitations. Firstly, we didn’t review all UAV regulations because it needs a considerable amount of efforts to check out all the UAV regulations pertinent to different areas of the world. It is the same case for manned aviation as we used only ICAO Annexes to contextually compare with UAV regulations. A broader overview regarding the world-wide UAV regulations can be found on Stöcker et al. (2017)’s and Yaacoub et al. (2020)’s studies. Jeanneret and Rambaldi (2016)’s working paper may give a detailed review of country-based UAV regulations. Secondly, only the common practice approaches were taken into consideration in international UAV regulations of ICAO, EASA, and Eurocontrol. Articles in the regulations were not given one by one as this paper focuses on the issue with a broad perspective. In future, under the legislative view, new UAV regulations with their context, effects and foundations can be studied to improve the applicability of regulations. Moreover, UAV regulations on the national level can be benchmarked via secondary data. From the practical perspective, studies introducing new technologies such as systems that help detection of remote pilots causing trouble and agile defense systems will give valuable insights to remove individual UAV threats. Declaration of Conflicting Interests The authors declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article. Funding The authors received no financial support for the research, authorship, and/or publication of this article. -44- Journal of Airline and Airport Management 12(1), 29-47 References Anwar, M. Z., Kaleem, Z., & Jamalipour, A. (2019). Machine learning inspired sound-based amateur drone detection for public safety applications. IEEE Transactions on Vehicular Technology, 68(3), 2526-2534. https://doi.org/10.1109/TVT.2019.2893615 Azari, M. M., Sallouha, H., Chiumento, A., Rajendran, S., Vinogradov, E., & Pollin, S. (2018). Key technologies and system trade-offs for detection and localization of amateur drones. IEEE Communications Magazine, 56(1), 51-57. https://doi.org/10.1109/MCOM.2017.1700442 Clarke, R. (2014). The regulation of civilian drones’ impacts on behavioural privacy. 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